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Respondent concedes that petitioner is not liable for an
addition to tax pursuant to section 6651(a)(1).
Respondent concedes that petitioner is not liable for an
addition to tax pursuant to section 6654(a).
Conclusion
For the reasons stated herein, we find and hold that there
is no genuine issue as to any material fact remaining for
litigation in this case and that a decision may be rendered as a
matter of law.
To reflect the foregoing,
An order granting
respondent’s motion for
summary judgment will be
issued, and decision will
be entered pursuant to
Rule 155.
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Last modified: May 25, 2011